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less, sec. 6673(a)(1)(B).
In Pierson v. Commissioner, 115 T.C. 576, 581 (2000), we
issued an unequivocal warning to taxpayers concerning the imposi-
tion of a penalty under section 6673(a) on those taxpayers who
abuse the protections afforded by sections 6320 and 6330 by
instituting or maintaining actions under those sections primarily
for delay or by taking frivolous or groundless positions in such
actions. In the petition and in petitioner’s motion and his
response to respondent’s motion, petitioner is raising, we
believe primarily for delay, arguments and contentions that we
have previously rejected, thereby causing the Court to waste its
limited resources.12 We shall impose a penalty on petitioner
pursuant to section 6673(a)(1) in the amount of $10,000.
We have considered all of the arguments and contentions that
petitioner advances in petitioner’s motion and petitioner’s
response to respondent’s motion, which are not discussed herein,
and we find them to be without merit and/or irrelevant.
On the record before us, we shall deny petitioner’s motion,
and we shall grant respondent’s motion.
12Petitioner is well aware of the Court’s views regarding
the allegations of error that he raised in the petition. They
are essentially the same allegations that he raised as the
representative for the taxpayer in Davis v. Commissioner, supra,
and for the taxpayer in Wylie v. Commissioner, supra.
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